Walsh v. The Queen, 2009 DTC 1372, 2009 TCC 557 -- summary under Paragraph 227.1(2)(a)

By services, 28 November, 2015

After the Court refused the admission into evidence of a copy of a letter from the Sheriff's Office advising that the Writ of Seizure and Sale had been returned unsatisfied, on the basis that this document had not been included in the Crown's List of Documents, Sheridan, J. went on to find that the Minister had failed to satisfy the burden of proof on it that s. 227.1(2)(a) had been satisfied. The taxpayer's appeal was allowed.

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